Outline of UN R0

Sub-group “UN R0” of IWVTA Informal Group

Transmitted by the experts of Japan, Germany, UK, the Russian Federation and OICA

Doc.No.IWVTA-SGR0-08-04

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Introduction of UN Regulation No. 0 (UN R0)

Introduction

UN R0 seeks to establish an internationally recognised whole vehicle type approval (IWVTA) scheme within the framework of the 1958 Agreement.

IWVTA scheme raises the advantages of individual UN Regulations from a component and/or vehicle system level to the whole vehicle and so creates opportunities to simplify implementation by Contracting Parties towards the wider adoption of mutual recognition for whole vehicles.

Mutual recognition of approval of vehicle systems and parts

Vehicle type approval required to be obtained from each country

Current System

Mutual recognition of approval at the whole vehicle level

Vehicle type approval not required to be obtained from each country

System in Our Goal

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Objective of IWVTA (1)

The major objective of IWVTA procedure is enhancement of the mutual recognition of vehicle type approvals by the means of:

Achieving wider acceptance of the vehicle/component type approvals pursuant to the UN Regulations;

Achieving more transparency about the national vehicle type approval procedures in the countries applying the IWVTA regulation;

Minimizing administrative burdens in obtaining national/regional vehicle type approvals;

Providing for flexibility in the requirements applied at national level, thereby helping those Contracting Parties developing new vehicle approval requirements.

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Objective of IWVTA (2)

Realizing objectives is beneficial for

Governments in delivering transparent, robust and reliable processes for vehicle type approval;

Industry by having access to quicker and more cost efficient type approval;

consumers, who benefit from vehicles meeting uniform and consistent requirements at lower prices.

Stepwise Approach (1)

These objectives cannot be reached from the very beginning due to the current level of harmonization between the national requirements of CPs.

In the first version of UN R0, the number of key provisions is not sufficient to certify a whole vehicle “partial IWVTA.”

At a later stage, partial IWVTA should develop into a complete whole vehicle type approval.

Stepwise Approach (2)Step １ : I-WVTA is a shell over a set of separate UN-approvals, which is agreed as common ground by all CPs applying I-WVTA

NationalWVTA

I-WVTA

I-WVTA

Step2: I-WVTA is a shell of all separate type approvals (both UN and national)

Step3: Complete mutual recognition of whole vehicle type approval, UN-approvals cover all relevant vehicle systems

Check for a complete vehicle and COP

I-WVTA

I-WVTA

National-approvalsNational WVTA

activities

NationalWVTA UN-approvals National-approvals

UN-approvalsCheck for a complete

vehicle and COPNational-approvals

NationalWVTA

UN-approvals

UN-approvalsCheck for a complete

vehicle and COPNational-approvals

NationalWVTA

Pragmatic and Desirable Goal at March 2016

National WVTA activities

National WVTA activities

National WVTA activities

Clarification

Step １ (clarification): I-WVTA is a shell over a set of separate UN-approvals, which is agreed as common ground by all CPs applying I-WVTA

While the visualisation scheme helps to understand the process, some explanation is missing that was provided by OICA in IWVTA-04-10. For persons not involved in IWVTA it will be difficult to understand the difference between Step 1 and Step 2, therefore explanation on the meaning on national approvals compared to national WVTA activities is needed. In other words: the question „what is the difference between step 1 and step 2?“ has to be explained.

Comment 1. on the slide “Stepwise Approach (2)”

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Contents of UNR0 as Step1 (first draft)

1. Scope2. Definitions3. Application for approval 4. Approval 5. Specifications 6. Tests 7. Modification of vehicle type and extension of approval 8. Conformity of production 9. Penalties for non-conformity of production 10. Production definitely discontinued 11. Names and addresses of Technical Services responsible for conducting approval

tests and of Administrative Departments 12. Introductory and transitional provisions 13. Special provisions for Contracting Parties applying this Regulation Annex 1: Communication Annex 2: Arrangement of the approval mark Annex 3: Procedures to be followed during I-WVTA of vehicles Annex 4: List of requirements for the purpose of I-WVTA: List of

regulatory acts Annex 5: Information document for the purpose of I-WVTA of vehiclesAnnex 6: Definition of the vehicle type

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1. Scope applicable only to vehicles of categories M1;

2. Definitions

Universal IWVTA (U-IWVTA) Type approval pursuant to the highest level of

stringency of the latest version of UNR0. CPs applying UN R0 shall accept U-IWVTA.

IWVTA with limited recognition (L-IWVTA) Type approval to earlier versions than those specified in

Annex 4, section 1 or the absence of type approvals. If CPs wishes to use the concept of an IWVTA with

limited recognition, it shall notify to the UN Secretarial all those Regulations for which it will accept either type approvals to earlier versions or the absence of type approvals.

For such notification, the format provided in Annex 4, section 2 shall be used.

Contents of UNR0 as Step1 (first draft)

UN-R A.nn

…

UniversalIWVTA

UN-R B.nn

UN-R C.nn

UN-R D.nn

UN-R E.nn

UN-R F.nn

UN-R A.nn

…

IWVTA of limited

recognition

UN-R B.nn-1

UN-R C.nn

UN-R D.nn-2

UN-R E.nn

UN-R F.nn

Recognizing that CPs are in largely different situations in terms of the amount and stringency of requirements necessary for national/regional whole vehicle type approval Regulation No. 0 provides for a flexible IWVTA scheme.

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13. Special provisions for CPs applying UNR0

13.1 & 13.3. Obligations of CPs applying UNR0 CPs applying UNR0 do not necessarily have to apply all UN Regulations

listed in the annex of UNR0 but they have to accept universal IWVTA. CPs applying UNR0 shall accept, for the purpose of granting an IWVTA,

all type approvals granted by other CPs according to the UN Regulations concerned even if they do not apply all these individual UN Regulations.

13.2 Rights of CPs applying UNR0 CPs applying UNR0 can issue IWVTA but criteria is based on whether

CP has the technical competence, not whether CPs applying UN R0 apply all regulations necessary for IWVTA.

13.5 Use of IWVTA of Limited Recognition If CPs accept L-IWVTA, they will accept either type approvals to earlier

versions or even the absence of type approvals as notified. For all vehicle systems, equipment and parts approved therein approvals

to later versions of the individual Regulations than those notified shall also be accepted.

Contents of UNR0 as Step1 (first draft)

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Annex 4: List of requirements for the purpose of IWVTA It is up to the decision of CPs to the 1958 Agreement which Regulations to

include in UNR0. Number of CPs covered and Number of regulations covered should be

balanced based on needs among CPs in consultation with industry when UNR0 is drafted. ⇒ Comment 2

All entries in tables are only provided for illustration of the concept.Section 1: List of Requirements for Universal IWVTA

Technical requirements for UNR0 are not explicitly contained in UNR0 itself, but are incorporated by reference to a list of UN technical regulations which can be found in Annex 4.

Contents of UNR0 as Step1 (first draft)

Number Topic UN-Regulation Series of amendments1 Radio interference 10 042 Door latches + hinges 11 033 Steering impact 12 044 Braking system 13-H 005 Belt anchorages 14 076 Safety belts 16 067 Seats + head restraints 17 08… …

Section 2: Provisions and requirements for IWVTA with limited recognition Standardized form for CPs to notify the UN-Secretariat about what will be acceptable to CPs under the limited recognition scheme.

This provision is not clear at the moment and depends on the proposal to be forwarded by the IWVTA Inf.G to WP.29. Discussion on this bullet point to be taken at the Bonn meeting.

Comment 2.

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IWVTA Inf.G had agreed on approach for application of UNR0 and now asks for WP.29 consent on the following issues:

1. Obligation of CPs applying UNR0: CPs applying UNR0 will have to accept U-IWVTA even if they are not

applying all UN Regulations listed in Annex 4, Section 1 of UNR0. CPs applying UNR0 will have to accept, for the purpose of issuing

IWVTA, type approvals issued by other CPs according to the UN Regulations listed in Annex 4, Section 1 of UNR0 even if they are not applying these UN Regulations

2. Right of CPs applying UNR0: CP applying UN R0 without applying some UN Regulations in Annex 4,

Section 1 of UNR0 will be allowed to grant U-IWVTA and/or IWVTA of limited recognition provided that it has ‘technical competence’ defined in UNR0 as follows.

Having regard to Article 2 of the 1958 Agreement ‘technical competence’ means that a Contracting Party has the capability to verify the compliance of a whole vehicle type with UN Regulation No. 0 based on the component type approvals submitted by the manufacturer in the application, and the ability to confirm that the systems and components are installed pursuant to the individual UN Regulations listed in Annex 4 of UN Regulation No. 0.

Subject for a Consent by WP.29 (1)

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Subject for a Consent by WP.29 (2)3. Upgrade of UNR0

Taking into account the number of new UN Regulations and amendments to existing UN Regulations adopted by WP.29/AC.1 three times a year, it is proposed to upgrade UNR0 one time in a year.

When the list of Section 1 of Annex 4 to UNR0 is extended to include new series of amendments to existing UN Regulations and new UN Regulations, this will create a new Series of Amendments to UNR0 change of the IWVTA numbering and marking. 　⇒ Comment 3, 4, 5, & 6

The introduction dates for series of amendments to individual regulations have to be synchronised with updates to UNR0 (due to the range of topics included in IWVTA). 　⇒ Comment 5

4. Exchange of information between CPs It is proposed to create and maintain the status document on UN

Regulations and their levels accepted or mandated, including national/regional requirements mandated for the whole vehicle approval process at national/regional level.

5. How to decide which UN Regulations are applicable to IWVTA Step 1 Number of CPs covered and Number of regulations covered should be

balanced based on needs among CPs in consultation with industry when UNR0 is drafted. ⇒ Comment 2

What does this mean in practice? Introduction of new requirements means introduction of a new series of amendments. If that introduction were made in the form of supplements, it should be noted that supplements do not have the same legal basis and cannot be used to identify the level of compliance).

Comment 3.

What does this mean in practice? Amendments will be needed for any substantive change to the Regulation as supplements do not have the same legal basis and cannot be used to identify the level of compliance.

Comment 4.

Comment 5. Before asking WP.29 for guidance on this, we should clarify the IWVTA Inf.G and SGR0 position.

Comment 6. This needs to be discussed in Bonn (personally, I am not sure to understand the purpose of such supplement if nothing new is added to UN R0). Based on the results in Bonn, we may need to amend this wording

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Future evolution of UN R0

The major objective of the IWVTA procedure is enhancement of the mutual recognition of vehicle type approvals. The ultimate goal for IWVTA is foreseen as a complete mutual recognition of whole vehicle approval, without any additional national requirements or approvals remaining.

To move forward to Step 2 + 3, at least, the followings should be addressed after the frame of UN R0 is established at March 2016.

- How to include the concept of a Certificate of Conformity (CoC) - How to reduce national requirements - How to increase the number of applicable UN Regulations in Section 1 - How to extend the scope to include vehicles other than M1

Ultimate goalStep 3

Mar. 2016

XXX. 20XX

Step 2

XXX. 20XX

（ Tentative slide: Future evolution approach should be considered at SG. )

Review is necessary, especially regarding the timing for the different items to be addressed in future, e.g. inclusion of other categories than M1 seems to be premature in step 2 and is not in line with the overall scheme presented in slide 6 .

Comment 7. on the slide “Future evolution of UN R0”